MACRA Jason Felts, MS HIT Practice Advisor
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Mission of OFMQ OFMQ is a not-for-profit, consulting company dedicated to advancing healthcare quality. Since 1972, we’ve been a trusted resource through collaborative partnerships and hands-on support to healthcare communities.
OFMQ Areas of Expertise • Analytics • Case Review • Education • HIPAA • IT Consulting • Health Information Technology • National Quality Measures • Quality Improvement
HIT Service Lines • HIPAA/Meaningful Use Security Risk Assessment - Level 1, 2, and 3 • Meaningful Use Assistance • Meaningful Use Audit Support • Risk Management Consulting and Development • Staff HIPAA Security Training • Website Development & Secure Email • IT Consulting
Jason Felts, MS • Jason Felts has more than eight years of experience in healthcare and currently works as a Health Information Technology (HIT) Practice Advisor. Throughout his time with OFMQ Jason has worked on multiple Health IT and quality improvement projects through the Office of the National Coordinator for Health IT, the Centers for Medicare and Medicaid Services, the Agency for Healthcare Research and Quality, and the Oklahoma State Department of Health. Jason works as a consultant to multiple physician practices and hospitals throughout the state on EHR incentive programs, workflow redesign, privacy & security, and many other healthcare related matters.
Overview of the MACRA • What is MACRA? • Who’s eligible? • When does it take effect? • Participation options • Next steps…
MACRA • Medicare Access & CHIP Reauthorization Act of 2015 – Bipartisan legislation signed into law April 16, 2015 – Notice of Proposed Rule Making released April 27, 2016 – Repeals the Sustainable Growth Rate (SGR) formula • Factor in reimbursement rates – New framework to reward clinicians for the value and quality of care they provide • “Quality Payment Program” (QPP)
Quality Payment Program • The new QPP will include 2 pathways: Advanced Merit-based Alternative Incentive Payment Payment Models System (MIPS) (APMs)
MIPS Eligibility • MIPS eligible clinicians include: – Physicians (MD/DO) – PAs – Nurse practitioners – Clinical nurse specialists – Certified registered nurse anesthetists • Plans to include other clinicians in the future (physicals therapists, occupational therapists, registered dieticians, etc.)
MIPS Eligible Clinicians ECs can participate in MIPS as Individual vs. Group an individual or a group • A group, defined by TIN, would be evaluated as a group practice across all 4 MIPS performance categories
MIPS Exemptions • Newly Medicare-enrolled ECs – First year of Part B participation • Clinicians below low patient volume threshold – Medicare charges ≤ $10,000 and fewer than 100 Medicare patients in one year • Certain participants in Advanced APMs • MIPS does not apply to hospitals or facilities (i.e. FQHCs, RHCs, Skilled Nursing)
Proposed MIPS Timeline 2017 2018 2019 • Performance • Reporting and • MIPS Period (Jan-Dec) Data Collection Adjustments in • 1 st Feedback • 2 nd Feedback Effect Report (July) Report (July)
Payment Adjustments 2022 onward 2021 +/- 9% +/- 6% 2020 +/- 5% 2019 Based on a MIPS Composite Performance Score, clinicians will +/- 4% receive a +/- or neutral adjustment
APMs • Give CMS new ways to pay health care providers for the care they give • QP – Qualifying APM Participant • Examples include: – Accountable Care Organizations (ACOs) • Groups of providers that voluntarily come together to provide coordinated care – Patient Centered Medical Homes (PCMH) – Bundled payment models • Bundle payments for multiple services during one episode of care
Advanced APMs • Models or programs in which clinicians accept both risk and reward for providing coordinated, high-quality, and efficient care. • These models must meet criteria for payment based on quality measurement and the use of EHRs. • There are specific criteria for determining what qualifies as an Advanced APM
Advanced APMs • Clinicians who participate to a certain extent would be exempt from MIPS payment adjustments and qualify for a 5% Medicare Part B incentive payment. • To qualify for incentive payments, clinicians must receive enough of their payments or see enough patients through the Advanced APM.
List of Advanced APMs • CMS would update this list annually to add new payment models Comprehensive ESRD Medicare Shared Care Model (Large Savings Program – Dialysis Organization Track 3 arrangement) Comprhensive Next Generation ACO Primary Care Plus Model (CPC+) Oncology Care Model Medicare Shared Two-Sided Risk Savings Program – Arrangement Track 2 (available 2018)
MIPS PERFORMANCE CATEGORIES & SCORING
• 4 Performance Categories: – Quality – Cost (Resource Use) – Clinical Practice Improvement Activities – Advancing Care Information
MIPS Composite Performance Score Clinical Practice Cost Improvement 10% Activities 15% Quality 50% Advancing Care Information 25% • Weight given to each section may change depending on performance and CMS focus
Quality • 50% of total MIPS score in year 1 • Replaces PQRS • ECs will select 6 measures – 1 cross-cutting measure and 1 outcome measure – Select from individual measures or a specialty measure set • Proposed quality measures available in the NPRM (Measures will be posted to the Federal Register no later than November of each year).
Cost • 10% of total MIPS score in year 1 • Also known as “resource use” • Replaces the cost component of the value modifier program • Based on Medicare claims (i.e. no reporting requirements) • 40 episode-specific measures to account for different specialties
Clinical Practice Improvement Activities • 15% of total MIPS score in year 1 • ECs rewarded for different activities such as: – Care coordination, beneficiary engagement, and patient safety • Big Quality Improvement (QI) component • ECs may select from a list of more than 90 options – Minimum of 1 CPIA activity to not receive a zero score • Clinicians can receive credit in this category for participation in APMs or PCMH
Advancing Care Information • 25% of total MIPS score in year 1 • The new Meaningful Use • EHR reporting, aligns with proposed stage 3 MU • * For clinicians whom the objectives are not applicable (i.e. hospital- based), CMS proposes to reweight the other MIPs categories
Meaningful Use Advancing Care Information • More focused on outcomes, promoting innovation and prioritizing interoperability 1. Reward providers for outcomes technology helps them achieve with patients 2. Allow flexibility to customize health IT 3. Level technology playing field (open APIs and low barriers to entry) 4. Prioritize interoperability – focus on “real - world” applications
Advancing Care Information - Scoring Base Bonus Performance Composite Score Score Score Point Base Score = 50 points Performance Score = 80 points Bonus Point = 1 point Composite Score = earn 100 or more points and receive full 25 points in the ACI category of MIPS Composite Score (*131 total available points)
Base Score • Accounts for 50 points of the total ACI score. • Provide numerator/denominator or yes/no for each objective and measure. • 6 proposed objectives – Proposed rule would no longer require reporting on Clinical Decision Support and the Computerized Provider Order Entry objectives – Only requires reporting to public health immunization registry
Objectives Protect Patient Electronic Patient Electronic Health Information Prescribing Access Coordination of Public Health and Care Through Health Information Clinical Data Patient Exchange Registry Reporting Engagement
Performance Score • Accounts for up to 80 points • Select measures from objectives that emphasize patient care and information access Coordination of Patient Electronic Care Through Health Information Patient Access Exchange Engagement
Advancing Care Information Objectives & Measures Objective Measure Protect Patient Health Information Security Risk Analysis Electronic Prescribing eRx Patient Electronic Access Patient Access Patient Education Coordination of Care Through Patient View, Download, Transmit (VDT) Engagement Secure Messaging Patient-Generated Health Data Health Information Exchange Exchange Information with other Clinicians Exchange Information with Patients Clinical Information Reconciliation Public Health Reporting Immunization Registry (*Required) Syndromic Surveillance, Electronic Case Reporting, Public Health Registries, Clinical Data Registries
When do the ACI objectives start? • Your reporting period will begin January 1, 2017. • The objectives you attest to will depend on the version of Certified EHR Technology you are using. • 2014 vs. 2015 Edition certification criteria – This will determine whether you attest to modified stage 2 or stage 3 criteria • 2015 CEHRT required for all clinicians in 2018
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